AML Policy

It is the policy of the Elementary Marketing Ltd (T/A Trakkit) to comply with all applicable statutes, regulations and government guidance regarding Anti-Money Laundering Regulations and terrorist activities. All policies adopted by Trakkit will be reasonably designed to protect us from being used for money laundering purposes or the purpose of facilitating terrorist activities.

What is Money Laundering?

Money laundering is a term used which relates to offences involving the proceeds of crime or terrorism funds.

To enter into or become concerned in an arrangement which you know or suspect will assist the acquisition, retention, use or control of criminal property or on behalf of another person (POCA section 328).

Acquiring, using or possessing criminal property.

COMPANY PROCEDURES UNDER THIS POLICY

For each customer (where appropriate) we will:

Verify customer identity and where necessary understand the source of funds and the source of payment

Screen customers in accordance with this policy

Take appropriate action once any possible suspicious activity has been detected and submit the appropriate report to the appropriate authority

RISK ASSESSMENT

While all financial transactions have the potential to present some level of money laundering risk, our process will centre on the following:

Customers or Entities – cash intensive businesses, money services businesses, casinos and other gambling related activities, dealers in high value or precious goods, intermediaries where the underlying customer is not disclosed.

Products – which allow the customer to convert cash into another monetary instrument, which allow the customer to move money from one jurisdiction to another and bulk cash transactions.

Services – transactions over the internet or by telephone and electronic fund transfers.

Politically exposed persons – is someone who has been entrusted with a prominent public function, or an individual who is closely related to such a person such as a spouse, parent, child or senior advisor.

Red flags – any abnormal circumstances in a transaction or behaviour that indicates potentially suspicious activity involved in money laundering or terrorist activities such as complex or unusually large transactions, unusual patterns of transactions which have no apparent economic or visible lawful purpose or any other activity which could be considered to be related to money laundering or terrorist financing.

REPORTING OF SUSPICIOUS ACTIVITY

Filing of a suspicious activity report is confidential and under no circumstances should the filing of a report be discussed with persons outside the Company.

The Money Laundering Officer has the sole responsibility of deciding whether to refer suspicious activity to the Serious Organised Crime Agency (SOCA).

RECORD KEEPING

The following records are required to be kept for 5 years:

Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed

Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed

The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations

REVIEW

This policy will be reviewed annually and in response to any regulatory changes which may come into force prior to the review period having expired.